In our continuing series of the FinCrime Files, we caught up with Gregory Dellas, Chief Compliance & Innovation Officer at ECOMMBX.
After a 22-year long career in the Cyprus banking sector, I am the current Chief Compliance and Innovation Officer for ECOMMBX, an electronic money institution licenced from the Central Bank of Cyprus. We specialise in B2B e-account management, cross-border payments and currency conversions. So, we mainly work with corporate customers from all over the world who want to use our innovative payments platform, ECOMMBANX to execute their payments, whether inward or outgoing, easily, quickly and at a reasonable cost.
In ECOMMBX I am responsible for the compliance programme of the company and managing the process of innovation and change management.
I started my career in Coopers and Lybrand in Nicosia and then joined Bank of Cyprus as a Private Banker. In the course of my career I held various senior and managerial positions in Cyprus Popular Bank and the Bank of Cyprus in wealth management, compliance and other areas.
In my previous role, at the Bank of Cyprus, I led the wealth management division of the bank, steering a team of over 100 people in private banking, institutional wealth, brokerage, asset management and global custody. Previously, I led the anti-money laundering (AML) risk management team within the International Banking Services Division and acted as the local compliance officer. My team was responsible for the onboarding of high-risk clients, the evaluation of large and complex transactions, as well as the review of existing and approval of new high-risk client relationships. In addition, I was also responsible for providing advice, guidance and specialized training to management and staff on AML and regulatory compliance matters. In the past, I also led the creation of private banking units in the U.K. and Romania and served as the group money laundering compliance officer, responsible for the AML function for Cyprus Popular Bank and all its overseas branches and subsidiaries.
My involvement with ACAMS started just over five years ago when I joined a couple of their conferences and was amazed and overwhelmed by the level of knowledge in the room and the decisiveness of anti-financial crime professionals to join forces and do the right thing.
I decided to join the effort and was very excited to be working with ACAMS to launch the Cyprus Chapter at a time when Cyprus was being questioned as regards its AML regulations and their implementation.
Since then, the Chapter provided me with the opportunity to network with like-minded professionals in Cyprus and abroad, accelerate my knowledge and experience in AML and TF but also introduced me to a number of people, I am now proud to call friends, who are also passionate to do something about stopping financial crime.
In the meantime, I also worked towards becoming CAMS certified, Advanced CAMS-Audit certified and a certified CAMS instructor. I was involved with ACAMS in the production of a number of their certificates and certifications as a subject matter expert including the newest CGSS and Advanced CAMS-RM certifications.
ACAMS produces great well-thought certifications but also provides a lot of resources for today’s AFC professional. There are free and paid webinars and a number of other free resources available. I believe all of these are important to keep one current and alert of changes in the regulatory environment. Also a lot of these resources are really practical, providing good reference for when working on your own risk management framework to fight financial crime. After all, we need to keep informed – as Albert Einstein once said “once you stop learning you start dying” – one of my mottos for most of my career.
For me it is quite straight forward:
Today’s compliance officer has become a focal point in most organisations, not only financial institutions. That means people rely on the compliance officer to provide them with opinions, answers to numerous questions, guidance and advice. This is quite flattering but it is not an easy job, especially for the less experienced professional.
Also, latest regulatory initiatives on responsibility and accountability seem to be more focused on who is to blame rather than what is to blame when there is failure. Accordingly, the environment for those working in compliance is becoming increasingly stressful, and stress brings with it a considerable amount of fear; fear of being liable, fear of loosing one’s job, fear being sanctioned.
That leads to mainly three things:
Having 360° experience (both in the front line and AML compliance) I understand how challenging it is to find the right balance. And that is why I believe, compliance professionals should spend some time in the front line or first line of defence, and vice versa. It is important to understand each other and speak the same language when dealing with customers and their issues.
What compliance professionals sometimes fail to understand is that clients are good! We want the right clients in our organisation and compliance professionals should be encouraged by regulators and senior management to feel confident to use critical thinking and critical judgment, take calculated decisions and, at the same time, encourage others, across their organisation, to do the same.
In my opinion, the UBO registers is a good step towards transparency. At the same time, I also see a few issues including:
Having said that, it is a step in the right direction provided that the information on the registers is used to support the KYC process and does not replace it.
Obviously as a Fintech we are very tech-centric and as a regulated company we have a full BCP (business continuity plan) in place. Accordingly, it was not difficult for us to adapt. We continued to be fully operational utilising the most modern work practices, ensuring first and foremost the safety and health of our staff, at the same time making sure our customers can continue to benefit from our range of services.
All companies had to adapt in this fast-moving environment. In the past, working from home was a luxury very rarely used in Cyprus. Now, most companies that can work from home do so provided they have the right systems and security in place.
Personally, I have not seen a huge change. Fintechs are traditionally more flexible in their processes and can easily adapt to change. As far as our services are concerned, there has been no downtime for our customers, at least for those who continue operating normally themselves (because obviously some have been affected), it is business as usual.
I think technology is necessary nowadays with the way regulation is changing and demands are increasing. Technology can perform routine work for us, but it can also help detect red flags. So basically, technology helps enhance our pull of resources and become more efficient in how to deal with financial crime.
However, as previously mentioned, technology is not yet to the point where it can replace humans, but rather it can complement the work of humans and it can help humans do their job more effectively and more efficiently. Technology cannot think for us, it cannot yet exercise judgment but what technology can do is that can leave us with time to think, focusing our attention on the real risks and taking time to exercise judgment and take decisions. In that respect, technology is indeed irreplaceable.
On the other hand, we need to keep in mind that technology is also available to criminals who try to exploit it advantages and vulnerabilities to engage in crime and hide their ill-gotten gains. And to better take advantage of technology, it is vital for those working in anti-financial crime to understand how this can happen, in essence get in the shoes of criminals.
Well, there are so many out there and Covid-19 brought about a spike in the number of podcasts and webinars available.
Obviously ACAMS is a great resource for me, including moneylaundering.com which is amazing for real-time information on regulations and AFC investigations.
I love listening to the new podcast series, Captivated Audience, run by Samantha Sheen of Exante Advisory Ltd, and a co-host. This was born during the lockdown and I thought it was a great idea and the information and opinions shared are really amazing. Also, C Notes, a webcast by Kevin Sullivan, author of Anti-Money Laundering in a Nutshell, is a new great series. I consider myself privileged to have participated in both of the above.
Also, I should mention the great Financial Crime Matters, from Kieran Beer of ACAMS.
I love the work of Kristy Grant-Hart who is very practical in her approach to compliance, helping compliance officers around the world to make their job effectively. And I am also looking forward to reading John Cassara’s new book on “Money Laundering and Illicit Financial Flows: Following the Money and Value Trail”. John is the author of perhaps one of the best books on “Trade-Based Money Laundering”.
I also love watching money laundering related movies and series and also follow quite a few websites that share contents on current cases, analyses of fines and new regulations and legal requirements. A great movie for every compliance professional is obviously The Laundromat (released in 2019) with a great cast and a fantastic storyline. Also, Breaking Bad is an ML classic; I also liked Ozark, and I also recommend the latest season of Dirty Money from Netflix.